Summary of the policy against harassment & intimidation 

1. Introduction & Purpose
The company is committed to eliminating all forms of violence and harassment in the workplace, particularly sexual harassment, in accordance with Law 4808/2021. The policy aims to foster a work environment that promotes dignity, respect, and equality.

2. Policy Objectives
- Inform personel about the concepts and rights related to harassment.
- Promote equality and non-discrimination.
- Strengthen cooperation between management and employees.
- Encourage prevention efforts.
- Provide immediate protection to victims and prevent retaliation.

3. Statement of Commitment
- Prohibition of all forms of discrimination, harassment or sexual harassment.
- Obligation to confidentiality for all parties involved.
- Zero tolerance – sanctions, including dismissal, will be imposed.
- Ensuring the prompt and confidential handling of complaints.

4. Scope of Application
This policy applies to all employees, external partners, trainees and anyone collaborating with the company.

5. Definitions & Forms of Harassment
- Harassment: Any unwelcome behavior that offends a person’s dignity.
- Sexual Harassment: Verbal, non-verbal or physical acts of a sexual nature without consent.
Indicative forms include:
- Harassment/Intimidation: Rumors, demeaning comments, isolation, criticism, humiliation.
- Sexual Harassment: Unwanted physical contact, sexist comments, suggestive innuendos, pressure to engage in a relationship, unsolicited messages, sexually explicit jokes.

6. Prevention & Response Guidelines

A. Prevention:
- Education and awareness-raising.
- Avoidance of comments or actions based on gender or sexuality.
- Establishment and respect of personal boundaries.
- Cooperation with Management in Implementing the Policy.

B. Response:
- Incidents must not be concealed or disregarded.
- Address the offender in a calm and composed manner.
- Maintain a detailed incidents log.
- Notify the Appointed Reporting Person.
- Use the standardized complaint form.

7. Company Responsibilities

A. Ensuring a Safe Environment:
- Prevention and Immediate intervention.
- Obligation to ensure non-repetition of incidents.
- Support for victims of domestic violence.

B. Preventive Measures:
- Dissemination of the policy.
- Promotion of a culture of respect.
- Informing personnel of legal rights and prohibited conduct.

8. Handling Complaints

A. Internal/Informal Procedure:
- Submission of the complaint to the Appointed Reporting Person.
- Assurance of confidentiality and use of mediation.
- Documentation and monitoring of the case.

B. Internal/Formal Procedure:
- Submission of a written complaint.
- Investigation by a Three-Member Committee.
- Implementation of measures (warning, transfer, disciplinary action, dismissal).
- Prevention of retaliation or false accusations.

C. Criminal/Civil Procedure:
- Complaints may be submitted to the Police, the Hellenic Labour Inspectorate (SEPE) or the Greek Ombudsman.
- The right to pursue legal remedies is not affected.

9. Appointed Reporting Person
The Appointed Reporting Person is the Operations Director, Konstantinos Karakaxidis, responsible for guiding, recording, and monitoring all related issues and procedures.